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• CChem ~Il • <br />90 East }falser Road <br />Parsippany, aJ 070ii <br />Tel: 973515.0900 <br />FiECEIVEQ <br />May 17, 1999 <br />MAY 19 1999 <br />Va Federal Express <br />Mr. Allen Sorenson <br />Reclamation Specialist <br />Division of Minerals and Geology <br />1313 Sherman Street., Room 215 <br />Denver, Colorado 80203 <br />pivision of Minerals 6 Gen~ogy <br />RE: Adequacy of the Application, Yankee Gulch Project, File No. M-99-002 (American <br />Soda) - Second Comment Submittal <br />Dear Mr. Sorenson: <br />We have reviewed the information provided by American Soda ("Applicant"). Based <br />upon our review, we object to the issuance of this permit. As of this writing, the Applicant has <br />not satisfied the issues outlined in the Colorado Division of Minerals and Geology ("DMG") <br />letter dated April 18, 1999 (RE: Adequacy of the Application, Yankee Gulch Project, File No. <br />M-99-022). The Applicant therefore, has failed to meet the minimum regulatory requirements of <br />the Colorado Mined Land Reclamation Act for permit issuance. If the DMG feels otherwise, <br />kindly contact us by telephone immediately to draw to our attention the manner in which the <br />inadequacies of the Applicant's permit application were met. <br />We have also reviewed the various supplementary information provided by Applicant <br />subsequent to the DMG's April 18, 1999 letter. Based on this information we object to a permit <br />issuance. In addition to our comment letter dated May 12, 1999, we offer this document to <br />express our serious concerns about the inadequacies contained within the Applicant's <br />supplementary information. Specifically, these concerns primarily relate to the intended <br />groundwater and surface monitoring plan. <br />General Chemical is in a unique position to evaluate the technical basis for this permit <br />application and provide assistance to the DMG and the Applicant. As you may be aware, General <br />Chemical has been successfully solution mining halite in an environmentally safe manner since <br />1918 in Amherstburg, Ontario. We are considered to be one of the leading industry pioneers and <br />have developed an extensive database of information on drilling, cavity and well development and <br />subsurface subsidence monitoring. To the extent our concerns remain unresolved we intend to <br />draw on expert testimony to argue the inadequacies of the reclamation permit application. <br />Accordingly, we offer the following guidance: <br />